Sipsmith Ltd (“we”; “us”; “our”) respects your privacy and is committed to protecting your personal information at all times in everything we do.
We are the data controllers in respect of the personal information which we hold about you. As data controllers, we are responsible for determining the purposes for which we use the information we hold about you.
In accordance with the General Data Protection Regulation ((EU) 2016/679) (the “GDPR”), this privacy notice sets out how we use your information in the course of operating our business and also sets out your legal rights in relation to the information we hold about you.
This privacy notice applies to our use of any personal information which we may collect from you through your use of this website, including any information you may provide when you purchase any product or service from us (e.g. distillery tours), sign up to our newsletters or take part in any competition or promotion sponsored by us. In addition, this privacy notice applies to our use of any information about you which we may collect from you via face-to-face communication, post, phone, email, social media or any other means of communication (including any form of electronic communication). This privacy notice also applies to any information about you which we may collect from any third party in the course of running our business.
THE INFORMATION WE COLLECT ABOUT YOU
We may collect, use, store and transfer a number of different kinds of personal information about you which we have grouped together as follows:
- Identity Data includes [name, title, date of birth and gender].
- Contact Data includes [billing address, delivery address, email address and phone numbers].
- Financial Data includes [bank account and payment card details].
- Transaction Data includes [details about payments to and from you and other details of products and services you have purchased / ordered from us, such as distillery tours].
- Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website].
- Profile Data includes [details of your username and password as a registered user of our website; purchases or orders made by you in relation to any products or services; subscriptions by you to any newsletters or to any products or services we provide; details of any interests, preferences, survey responses, feedback or complaints which you have communicated to us; and details which you have provided in relation to taking part in any competition or promotion sponsored by us].
- Usage Data includes [information about how you use our website, products and services].
- Marketing and Communications Data includes [name, email address, your preferences in receiving marketing materials, promotions and/or newsletters from us and your communication preferences].
We may also be required to process additional information about you from time to time in the course of operating our business where this is necessary for the purposes of administering our business correctly and/or promoting our products and services effectively.
Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have ordered from us but we will notify you if this is the case at the time.
HOW YOUR INFORMATION IS COLLECTED
We will mainly collect personal information about you through direct interactions with you. You may give us your personal information by filling in forms or by corresponding with us through our website or by post, phone, email, social media or any other means of communication (including any form of electronic communication). This includes personal information you provide when you: (i) order / purchase our products or services (e.g. distillery tours); (ii) register / create an account on our website; (iii) subscribe to receive our products, services, publications or newsletters; (iv) request marketing materials to be sent to you; (v) enter a competition, promotion or survey; or (vi) provide us with any feedback or other communications.
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies.
We may also collect information about you from other entities in our group, from our business partners and from various other third party service providers, including but not limited to professional advisers, analytics providers, advertising networks, search information providers, fraud prevention and credit reference agencies and providers of technical, payment and delivery services.
It is important that the personal information we hold about you is accurate and up to date. Please let us know if your personal information changes at any time during your relationship with us.
HOW WE USE YOUR INFORMATION
We will only use your personal information where we have a lawful basis for doing so. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for the purposes of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those legitimate interests.
- Where we need to comply with any legal obligation or regulatory requirement.
We may also use consent as a lawful basis for providing you with marketing communications in certain circumstances. For further details, please see the Marketing section below.
The table below sets out a description of the main ways we plan to use your personal information and which of the relevant lawful grounds for processing we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you require details about the specific lawful ground we are relying on to process your personal information where more than one lawful ground has been set out in the table below.
|Purpose / Activity||Lawful grounds for processing|
|[Registering you as a new customer.]||[Necessary for the performance of a contract with you.]|
|[Processing and delivering your orders / purchases and providing you with products or services (e.g. distillery tours) in connection with any contract which you have entered into with us.]||[Necessary for the performance of a contract with you.]|
|[Communicating with you for the purposes of providing you with any products or services (e.g. distillery tours) which you have ordered / purchased from us.]||[Necessary for the performance of a contract with you.] [Necessary for our legitimate interests in operating our business correctly and promoting our products and services effectively.]|
|[Managing our relationship with you, including reviewing and responding to any questions, feedback or other communications submitted by you.]||[Necessary for the performance of a contract with you.] [Necessary to comply with our legal obligations.] [Necessary for our legitimate interests in operating our business correctly, promoting our products and services effectively, developing and improving our products and services and responding to queries or complaints effectively.]|
|[Managing and processing all payments, fees and/or charges and collecting and recovering any sums owed to us.]||[Necessary for the performance of a contract with you.] [Necessary for our legitimate interests in processing payments made by our customers and recovering any debts due to us.]|
|[Providing you with the opportunity to take part in competitions or promotions.]||[Necessary for our legitimate interests in promoting our products and services effectively and developing and growing our business.]|
|[Providing you with the opportunity to complete surveys and reviewing any survey responses or other communications submitted by you in relation to your experience of our products and services (e.g. distillery tours).]||[Necessary for our legitimate interests in studying how customers experience our products and services and developing and improving our products and services.]|
|[Administering and protecting our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).]||[Necessary to comply with our legal obligations.] [Necessary for our legitimate interests in operating our business correctly, ensuring the provision of effective administration and IT services, maintaining network security and preventing fraud.]|
|[Delivering relevant website content and online advertisements to you and measuring and understanding the effectiveness of the website content / advertising we serve to you.]||[Necessary for our legitimate interests in studying how customers use our products / services, developing and improving our products / services, keeping our website up to date and relevant, growing our business and informing our marketing strategies.]|
|[Using data analytics to improve our website, products / services, marketing, customer relationships and experiences.]||[Necessary for our legitimate interests in defining the types of customers for our products / services, keeping our website up to date and relevant, developing and improving our products / services, growing our business and informing our marketing strategies.]|
|[Providing you with marketing materials, newsletters and promotions and also providing you with suggestions and recommendations about products and services (e.g. distillery tours) that may be of interest to you.]||[Necessary for our legitimate interests in developing and promoting our products and services and growing our business.][In certain circumstances, we may use consent as a lawful basis for processing personal information for direct marketing purposes.]|
We may use your personal information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, promotions and/or offers may be relevant for you for the purposes of marketing.
You will receive marketing materials from us if you have requested this information from us. You may also receive marketing materials from us if you have purchased products or services from us (e.g. distillery tours), or engaged in negotiations with us in connection with our products or services, or if you have provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving marketing materials. In these circumstances, we will provide you with marketing materials on the lawful basis that it is necessary for the purposes of our legitimate interests in developing and promoting our products and services and growing our business.
If you have provided us with your details and none of the above circumstances apply, you will only receive marketing materials, email newsletters or email promotions from us in circumstances where you have provided an opt-in consent which confirms that you want to receive such marketing from us. In these circumstances, you have the right to withdraw your consent at any time to the use of your personal information for marketing purposes.
OPTING OUT OF MARKETING
You have the right to object at any time to the processing of your personal information for direct marketing purposes. If you object to such processing, we will cease to process your personal information for direct marketing purposes.
You can ask us to stop sending you marketing materials at any time by: (i) following the opt-out links on any marketing communication, email message or email newsletter sent to you; or (ii) contacting us by email at [email protected]
HOW LONG WE RETAIN YOUR INFORMATION
We will retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
DISCLOSURES OF YOUR INFORMATION
We may need to share your information with various third parties which provide services to us or act on our behalf in connection with the operation of our business. In particular, your information may be disclosed to the following categories of third parties:
- [Other entities in our corporate group.
- Professional advisers (including legal advisers and financial advisers), auditors, insurers, bankers, and financial organisations.
- Other third party service providers which provide services to us in connection with the operation of our business, including but not limited to: IT and system administration services and other technical services; website development services; data storage services; digital marketing and email deployment services; tour booking services; customer fulfilment services; logistics, distribution and delivery services; data analytics services; fraud prevention and credit reference services; and payment processing and receipt processing services.
- Trade associates and business partners.
- Third parties with whom we may enter into negotiations in respect of a commercial agreement, e.g. joint business venture.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
- HM Revenue & Customs or any other public authority or regulatory authority in circumstances where we are required to disclose personal information by law.]
We require all third party service providers to respect the security of your personal information and to treat it in accordance with the law. We do not permit our third party service providers to use your information for their own purposes and only permit them to process your information for specified purposes and in accordance with our instructions.
INTERNATIONAL DATA TRANSFERS
Please note that there may be instances where it may be necessary for us to transfer your information outside the European Economic Area, e.g. if we use third party service providers from another country. In these circumstances we shall put in place suitable safeguards to ensure that your information is held securely. If you require further information about the safeguards put in place you can request it from us by contacting us by email at the email address set out below.
YOUR LEGAL RIGHTS IN RELATION YOUR INFORMATION
Under the GDPR, you have a number of legal rights in relation to the personal information which we hold about you. We respect your legal rights in relation to your information and aim to uphold your rights in everything we do. Your legal rights under the GDPR include the following:
- Subject access right – You can ask us to provide you with a copy of the personal information which we hold about you and a description of how we use your information.
- Right to rectification – If you believe any information we hold about you may be inaccurate or incomplete, you can require us to rectify these inaccuracies.
- Right to erasure / Right to be forgotten – You can require us to erase your information in certain circumstances. However, please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Right to data portability – Where we process your information using automated means of processing on the basis of your consent or for the purposes of performing a contract with you, you can request that we supply such information to another party in a machine-readable format.
- Right to restriction of processing – You can require us to restrict or suspend our processing of your information in certain limited circumstances.
- Right to object to processing – Where we process your information on the lawful basis that such processing is necessary for the purposes of our legitimate interests, you have the right to object to us processing your information in certain circumstances.
- Right to object to processing for direct marketing purposes – You have the right to object at any time to the processing of your information for direct marketing purposes. If you object to us processing your information for direct marketing purposes, we will no longer process your information for such purposes.
- Right to withdraw consent – If we process your information on the basis of your consent, you have the right to withdraw your consent at any time to the processing of your information. However, please note that this will not affect the lawfulness of any processing of your information carried out before you withdraw your consent.
HOW TO CONTACT US
Please get in touch if you have any questions about how we use your information or you wish to contact us about your legal rights or if you have any complaints or feedback about our use of your information. Please contact us at any time by sending an email to us at [email protected]
If you wish to submit a complaint or express any concerns about our use of your information, please contact us in the first instance. We will do our best to resolve your complaint or address your concerns to your satisfaction. However, if you feel that we have not resolved your complaint or addressed your concerns, please note that you have right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues.
Please note that we may update this privacy notice at any time. Any changes to this privacy notice will be posted on our website, and where appropriate, notified to you by email.